Public Statements for the Taxation Community

• June 29, 2016 Comments on Proposed Treasury Regulations Issued Under Section 385 of the Internal Revenue Code
• March 10, 2016 Proposal to Modify Treasury Regulations Issued Under Section 336(e) of the Internal Revenue Code - Qualified Stock Distributions
• January 20, 2016 Statement of Support for the Revised Uniform Fiduciary Access to Digital Assets Act (RUFADAA)
• December 4, 2006 Letter to the Honorable Phil Mendelson regarding Bill 16-759, Nonprofit Organizations Oversight Improvement Act of 2006.
• December 21, 2005 Request for guidance from the IRS and the Department of the Treasury concerning the continued application of the Kimbell-Diamond doctrine
• July 7, 2004 Comment letter on I.R.S. Revenue Ruling 2004-43, 2004-18 I.R.B.842 (partnership "anti-mixing bowl rules")
• November 25, 2003 Comment letter on proposed I.R.S. and Treasury rules regarding assumption of liabilities in "nonrecognition transactions."
• February 4, 2003 Comments on Temporary and Proposed Regulations Regarding the Requirement to Maintain a List of Investors in Potentially Abusive Tax Shelters submitted by the D.C. Bar Taxation Section.
• February 2, 2001 Comments on application of provisions of the Internal Revenue Code governing exempt organizations to activities which those organizations conduct on the Internet and whether clarification is needed regarding the application of those provisions to such activities.
• November 2, 1998 Comments on proposed interim regulations on intermediate sanctions by the Internal Revenue Service.
• June 18, 1997 Letter to Dr. Natwar Gandhi, Deputy Chief Financial Officer for Tax and Revenue for the D.C. Government, about the administration of taxes. **
• May 6, 1997 Letter to Hon. J. Robert Kerrey and Hon. Rob Portman, Co-Chairs of the National Commission on Restructuring the Internal Revenue Service, concerning the future regulation of Employee Plans and Exempt Organization matters.
• December 12, 1996 Comments on I.R.S. regulations on " Intermediate Sanctions" legislation enacted as part of the Taxpayer Bill of Rights 2.
• December 9, 1996 Comments on 1997 Treasury/I.R.S. Guidance Priorities List.
• July 11, 1996 Comments in a letter to Evelyn A. Petschek, Assistant Commissioner, Employment Plans and Exempt Organizations, Internal Revenue Service, regarding proposed Precedential Guidance to be issued by the Internal Revenue Service.
• June 10, 1996 Comments in a letter to the Honorable James R. Murphy, Acting Chair, Board of Real Property Assessments and Appeals, regarding proposed rules of procedure to be adopted by the Board of Real Property Assessments and Appeals (BRPAA) for the District of Columbia.
• February 21, 1996 Comments regarding the Department of Labor's Proposed Regulation Relating to the Definition of Plan Assets; Participant Contributions.
• December 18, 1995 Comments in a letter to Margaret Milner Richardson, IRS Commissioner, and Leslie B. Samuels, Assistant Secretary, U.S. Treasury, commending the recent efforts of Treasury and IRS to present information (including prototype tax forms) to Congress regarding the potential complexity of proposed tax legislation.
• November 28, 1994 Comments in a letter to all members of the Senate Finance Committee regarding provisions of H.R. 3419, the Tax Simplification and Technical Corrections Act of 1993.
• July 18, 1994 Comments in a letter to Chairman David Clark and Council members of the Council of the District of Columbia, regarding Bill No. 10-711 - The Arena Tax Amendment Act of 1994. **
• July 15, 1994 Pre-regulation comments in a letter to the Honorable Leslie B. Samuels, regarding Section 108© of the Internal Revenue Code of 1986 pertaining to qualified real property business indebtedness.
• June 16, 1994 Pre-regulation comments to U.S. Dept. of Treasury and the I.R.S. on Section 469(c)(7) of the Internal Revenue Code of 1986 pertaining to passive loss relief for real estate professionals.
• May 9, 1994 Comments regarding Title III of D.C. Act 10-225, imposing a special public safety fee.
• September 23, 1993 Comments to the Internal Revenue Service regarding regulations under ERISA Section 204(h).
• April 21, 1993 Testimony before the Subcommittee on Oversight, Ways and Means Committee of the U.S. House of Representatives, regarding implementation of the Internal Revenue Service's Nonfiler Initiative.
• April 7, 1993 Comments on proposed regulation Section 1.704-3 pertaining to allocations in connection with built-in gain or loss property contributed to partnerships.
• December 22, 1992 Comments to Internal Revenue Service in a Letter to Hon. Shirley D. Peterson, Commissioner, on the Proposed Amendments to Circular 230, 31 CFR, Part 10, IA-20-92 RIN 1545-AQ56. **
• December 7, 1992 Comments on the Treasury Department/Internal Revenue Service 1993 Business Plan for Administrative Guidance. **
• April 6, 1992 Comments on the proposed District of Columbia Nonprofit Corporation Act of 1991, Bill 9-316.
• February 27, 1992 Comments on the proposed District of Columbia Professional License Amendment Act of 1992, Bill 9-454.
• February 11, 1992 Letter to John A. Wilson, Chairman of the Council of the District of Columbia, regarding the official comment procedures for the proposed tax on legal services. Included: Memo from James Robertson, D.C. Bar President, to Community Chairs, outlining expedited review procedures for comments on proposed tax on legal services. **
• November 25, 1991 Comment on certain estate and gift tax provisions of the Tax Simplification Act of 1991. **
• March 28, 1991 Comment on proposed regulations disallowing a deduction for interest paid on tax deficiencies by businesses under Section 6621 of the Internal Revenue Code, enacted by the Revenue Reconciliation Act of 1990. **
• March 22, 1990 Letter to Kenneth Klein, Associate Chief Counsel, I.R.S., recommending how the I.R.S. could use its resources more effectively in the ruling area.
• March 12, 1990 Proposed legal services tax legislation. **
• March 6, 1990 Proposed comments on the D.C. Professional Services Sales and Use Tax legislation.
• November 20, 1989 Letter to Messrs. Nicholas Brady, Richard Darman, Lloyd Bentsen and Dan Rostenkowski urging the legislative and executive branches of government to approve a larger allocation of budgeted funds to the I.R.S.
• July 31, 1989 Comments to the Commissioner of Internal Revenue Service regarding proposed regulations on lobbying by public charities.
• December 22, 1988 Comments on the draft report of the House of Representatives Ways and Means Committee's Oversight Subcommittee describing recommendations on the unrelated business tax.
• September 19, 1988 Proposed letter to Ronald A. Pearlman, Chief of Staff, Joint Committee on Taxation, re pending technical corrections to the welfare plan non-discrimination rules of Section 89 (H.R. 4333 and S. 2238).
• March 18, 1987 Proposed letter addressed to the Commissioner of Internal Revenue Service in opposition to proposed lobbying regulations to implement Section 1307 of the Tax Reform Act of 1976, PL 944 - 455.
• February 13, 1987 Proposed amendments to Circular 230, 31 C.F.R. Part 10.
• February 10, 1987 U.S. Department of the Treasury's proposed "due diligence" and "substantial authority" modifications to regulations practice before the Internal Revenue Service.
• May 6, 1986 Employee Benefits Committee: Letter to the Commissioner of the I.R.S., in opposition to proposed regulations on availability of alternative forms of benefits under qualified plans [Sections 1.401(a)-4 and 1.411 (d)-4].
• November 21, 1985 Letter to Joseph K. Dowley, Chief Counsel, House Committee on Ways and Means, in support of a legislation proposal to extend provisions of the Equal Access to Justice Act regarding reimbursement of attorney's fees to Section 7430 of the International Revenue Code.
• August 27, 1985 The President's proposal to limit the use of the cash method of accounting.
• April 29, 1980 Comments on the proposal to extend the sales and use tax to professional services before the Committee on Finance and Revenue of the Council of the District of Columbia.

**Full text not available.